Justification (Posting)_1.pdf

SOLE SOURCE JUSTIFICATION

SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

AUTHORITY: FAR 13.501(a), 41 U.S.C. 1901

CONTRACT #140D7018C0003; Modification P00010

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification.”

This is a sole source justification for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 5, Branch 2 conducted on behalf of DOI, Bureau of Trust Funds Administration (BTFA).

2. Nature and/or description of the action being approved.

This is a modification to existing Contract 140D7018C0003; Modification P00010. The contractor is:

Tuknik Government Services, LLC (TGS) 3800 CenterPoint Drive, Suite 502 Anchorage, Alaska 99503

DUNS 079495837

CAGE 7HDF1

The proposed action is to extend the contract for six months from February 20, 2021 through August 19, 2021 under Federal Acquisition Regulation (FAR) Clause 52.217-8—Option to Extend Services. The clause was included in the competitive solicitation and the awarded contract.

However, pricing was not evaluated as part of the original award. The extension will allow for the completion of ongoing data migration to the new Trust Funds Accounting System (TFAS).

In addition, as the TFAS conversion has progressed, the Statement of Work is de-scoped as the Government’s requirement for contractor support has been reduced.

This firm-fixed-price contract was competitively awarded as a commercial service under FAR 13.5 – Simplified Procedures for Certain Commercial Items and set-aside under the Buy Indian Act for Indian Small Business Economic Enterprises (ISBEE) in accordance with the Department of the Interior Acquisition Regulation (DIAR) Part 1480 – Acquisitions under the Buy Indian Act. The contract was awarded with a base period of two (2) years and a one-year option period expiring on February 19, 2021.

3. A description of supplies or services required to meet the agency’s needs (including the estimated value).

The extension is required to ensure that the BTFA has the continuity of Tuknik contractor personnel in place to continue to perform the critical tasks of data migration related to the TFAS conversion.

These required tasks include providing database maintenance and development, monitoring and adjusting extract-transform-load (ETL) for movement of TFAS data into the Enterprise Business Solution (EBS) data warehouse, supporting data analytics of TFAS data, supporting applications that modify data in TFAS, and various other tasks in support of the stabilization of the TFAS conversion.

The requirement has been descoped from the initial contract and option year one as based on the progression of the TFAS conversion, the tasks that were performed by the labor category of a support

CONTRACT #140D7018C0003

analyst are no longer required. A red-lined Statement of Work addressing the de-scope is a part of the modification.

The firm-fixed-price for this modification is $138,910.10. Therefore, the total firm-fixed-price of the contract will increase from $4,122,960.32 to $4,261,870.42; total contract obligation amount $3,141,828.89.

4. An identification of the statutory authority permitting sole source acquisition.

This is an acquisition conducted under the authority of the Simplified Procedures for Certain Commercial Items. The statutory authority permitting sole source acquisition is 41 U.S.C 1901 as implemented by FAR 13.501(a)(1)(ii). The authorities on the modification are 52.212-4(c) Changes and 52.217-8 Option to Extend Services.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Tuknik is uniquely qualified to continue with these services in an expedited manner because they are intimately familiar with each application related to their part of the TFAS conversion. Their expertise obtained through this contract is the most efficient means in working with the new TFAS system and if not allowed to continue certain services, it would harm the government due to lack of ongoing support. For these services to be provided by another contractor, they would require time to catch up in order to perform the requirements, which would result in a break of service, and require additional funding, which results in increase project cost and performance risk.

In addition, a break in service will negatively impact the ongoing TFAS migration for various applications. For example, some of the critical applications that will be supported for the TFAS are a part of the TFAS day-to-day functions. The TFAS supports the trust funds management, accounting and investment activities for approximately 400,000 open accounts and over 50,000 closed accounts.

The management of Indian trust assets on behalf of the trust beneficiaries is dependent upon the processing of trust-related transactions within certain information systems of the Department and the distribution of receipts and disbursements to beneficiaries by BTFA are significantly dependent and reliant upon fiduciary trust accounting systems, the TFAS, to ensure the accountability and dissemination of financial information.

Tuknik’s continued support is also needed as there were delays in the conversion to the new TFAS that was to occur in March 2019 but was not until October 2019. Thus, Government staff are not completely prepared to begin the continued migration tasks. This has also been impacted by the COVID pandemic as BTFA moved to a 100% telework environment and this contributed to the delay in the transition to the new TFAS.

Thus, Tuknik is needed for an additional six (6) months for the continuity of the migration of applications and the extension is the most advantageous method for the services to continue for

BTFA.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

For the aforementioned reasons under Section 5 above, offers were not solicited from other sources as this is an extension to the current contract in accordance with FAR clause 52.217-8 – Option to Extend Services. Due to the extreme risk of the TFAS program and the need for the continued migration support in the conversion of the SEI TFAS system to Innovest’s InnoTrust System, and with the knowledge of the current Tuknik contractor, other contractors have not been sought.

The justification will be made publicly available within 14 days after execution of the modification in accordance with FAR 13.501(a)(1)(ii).

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

Prior to the execution of this modification, the contracting officer will make a fair and reasonable price determination. The contracting officer may use historical data, contractor or contract pricing information, or other sources as necessary to make the determination that the price is fair and reasonable.

8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Market research was not conducted for seeking other sources due to the extent of the need for the continuity of the expertise of the existing contractor.

9. Any other facts supporting the use of other than full and open competition, such as:

None

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

No sources have expressed an interest in the acquisition.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

Contract 140D7018C0003 was conducted under FAR 13.5 and was a competitively awarded ISBEE set-aside and included FAR 52.217-8—Option to Extend Services; however, its pricing was not evaluated at time of contract award. Thus, there are no barriers to remove or overcome for this acquisition.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Anita K. Tolliver Date Contracting Officer

13. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Katherine L. Ramirez Date Contracting Officer’s Representative Bureau of Trust Funds Administration

14. Reviews and Approvals

Approve

Anita K. Tolliver Date

Contracting Officer